Policy Paper: Direct Certification and Verification in CA School Meals
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Policy Paper: Direct Certification and Verification in CA School Meals

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    Policy Paper: Direct Certification and Verification in CA School Meals Policy Paper: Direct Certification and Verification in CA School Meals Document Transcript

    • There IS such a thingas a free lunchEffective direct certification anddirect verification to ensure adequatenutrition for California’s childrenCathy HsuMarch 2009
    • AcknowlegementsThank you to our funders: the California Endowment, The Vitamin Settlement, KaiserPermanente and MAZON: A Jewish Response to Hunger for their support of our child nutritionpolicy advocacy.Thank you to the kind people at school food service departments and county offices throughoutthe state for taking the time to share their knowledge and experiences with me. Also, I want tothank those at California School Information Services and California Department of EducationNutrition Services Department for sharing their expertise and being instrumental in the editingprocess. And thank you to my colleagues at the California Food Policy Advocates, particularlyGeorge Manalo-LeClair, for their untiring guidance, feedback and support. Finally, a specialthank you to Zoe Neuberger with the Center on Budget and Policy Priorities for generouslysharing her wealth of knowledge with me and giving her time to help me write this paper. i
    • Table of ContentsGlossary of Acronyms and Abbreviations ..................................................................... iiiExecutive Summary ...........................................................................................................1Introduction ........................................................................................................................3School Meals: The Basics ..................................................................................................4Direct Certification ............................................................................................................6 Legislative History .......................................................................................................... 6 Process ............................................................................................................................. 6 Benefits............................................................................................................................ 7 Current Use in California ................................................................................................ 7 Achieving the Best Match ............................................................................................. 10 Recommendations for Improving the Match ................................................................ 10Direct Verification ...........................................................................................................15 Legislative History ........................................................................................................ 15 Process ........................................................................................................................... 15 Benefits.......................................................................................................................... 15 Best Uses ....................................................................................................................... 16 Current Use in California .............................................................................................. 16Addition of Medi-Cal to Direct Certification and Verification in California ............18 Legislative Authority..................................................................................................... 18 Potential of Medi-Cal .................................................................................................... 18 Process ........................................................................................................................... 18 Recommendations ......................................................................................................... 19Conclusions .......................................................................................................................21 References ..................................................................................................................... 23 Appendix A: Application for Free and Reduced Price Meals ....................................... 25 ii
    • Glossary of Acronyms and AbbreviationsAFDC Aid to Families with Dependent Children, which later became Temporary Assistance for Needy Families (TANF)CALPADS California Longitudinal Pupil Achievement Data SystemCalWORKS California Work Opportunities and Responsibility to KidsCDE California Department of EducationCDSS California Department of Social ServicesCSIS California School Information ServicesDHCS California Department of Health Care ServicesFDPIR Food Distribution Program on Indian ReservationsFNS Food and Nutrition ServiceFPL Federal Poverty LevelFS Food Stamp ProgramLEA Local Education AgenciesSCHIP State Children’s Health Insurance Program, known in California as Healthy FamiliesSSN Social Security NumberTANF Temporary Assistance for Needy Families, previously known as Aid to Families with Dependent Children (AFDC)USDA U.S. Department of AgricultureWIC Special Supplemental Nutrition Program for Women, Infants and Children iii
    • Executive SummaryAll children should have adequate nutrition in order to learn in the classroom – no matter whattheir family income. Children that can’t afford to pay full price for school breakfast or lunch canapply for free and reduced price lunches, but paperwork hassles often make it difficult to getenrolled. Recently, Congress, the California state legislature, Governor Arnold Schwarzeneggerand State Superintendent of Public Instruction Jack O’Connell have created exciting opportunitiesto decrease paperwork and get meals to the kids that need them. These opportunities involvedirect certification and direct verification, processes that use information from other means-testedprograms to confer and check eligibility for school meals. Improving direct certification,implementing direct verification and including Medi-Cal information are all steps that Californiacan take to ensure healthier and smarter kids at school.We hope that this paper may serve as an informative guide for administrators and advocates at thedistrict, county, state and federal level looking to enroll more children in school meals with lesspaperwork. By understanding the process and barriers to fulfilling its full potential, we can allcollaborate to ensure that children are not missing out on the important nutrition they need.CFPA’s recommendations for effective direct certification and direct verification:Direct Certification • LEAs should switch to the state match or use the state match in addition to the county match. • Comprehensive testing of criteria options should be conducted to identify the match criteria that will match the most eligible children while not matching ineligible children. • A benchmark of match coverage, such as the percent of eligible children matched to school enrollment, should be set and monitored. If match coverage does not reach the benchmark, action should be taken to identify and remedy the problem. • The match criteria should be loosened by eliminating any identifiers, such as address, that limit the number of LEAs able to participate and result in eligible children not being matched. • A multiple match process should be implemented to increase the number of eligible children matched. • Additional action should be taken with unmatched children on the FS and CalWORKs list, such as making the list available to LEAs and creating a sibling match. • CDE should continue with plans to increase the match frequency to monthly and CSIS should provide freedom to access the match list in a variety of ways. • CDE should increase communications regarding the availability and continual improvements of the state match. Both CDE and CSIS should provide additional outreach and trainings. 1
    • Direct Verification • Direct verification should be used when a system is in place to make use of Medi-Cal and Healthy Families data. • Communications to LEA staff should clarify that direct verification can be used for both categorical and income application.Adding Medi-Cal and Healthy Families • CDE should pursue the inclusion of income information for Healthy Families children in the statewide database to facilitate direct certification and direct verification for those children. • CDE should use the design and implementation efforts of the Medi-Cal and Healthy Families direct verification system to implement direct certification with Medi-Cal and Healthy Families in California as a pilot program or, if and when federal authority is clarified, as a permanent statewide effort. 2
    • IntroductionAll children should have adequate nutrition in order to learn in the classroom – no matter whattheir family income. Children that can’t afford to pay full price for school breakfast or lunch canapply for free and reduced price lunches, but paperwork hassles often make it difficult to getenrolled. Recently, Congress, the California state legislature, Governor Arnold Schwarzeneggerand State Superintendent of Public Instruction Jack O’Connell have created exciting opportunitiesto decrease paperwork and get meals to the kids that need them. These opportunities involvedirect certification and direct verification, processes that use information from other means-testedprograms to confer and check eligibility for school meals. Improving direct certification,implementing direct verification and including Medi-Cal information are all steps that Californiacan take to ensure healthier and smarter kids at school.We hope that this paper may serve as aninformative guide for administrators andadvocates at the district, county, state and To get more meals to more kids:federal level looking to enroll more children • Improve direct certificationin school meals with less paperwork. Byunderstanding the process and barriers to • Implement direct verificationfulfilling its full potential, we can all • Include Medi-Cal informationcollaborate to ensure that children are notmissing out on the important nutrition theyneed. 3
    • School Meals: The BasicsThe National School Lunch Program began in 1946 when the National School Lunch Actauthorized it as a program to “safeguard the health and well being of the nation’s children.”Many years later, in 1975, the School Breakfast Program was added. While both programsprovide meals to all children at a subsidized price, children from low-income households canapply for free or reduced price meals. The federal government provides reimbursement toschools for all meals served and provides a higher reimbursement for free and reduced pricemeals served. In addition, schools in California receive a supplemental reimbursement from thestate for free and reduced price meals.Table 1: California School Meals Eligibility and Reimbursement Rates1 Income Limit for Lunch Reimbursement Breakfast Reimbursement Eligibility (% Federal* State Federal+ State FPL) Free 130% $2.57 $0.22 $1.40 $0.22 Reduced Price 185% $2.17 $0.22 $1.10 $0.22 Paid NA $0.24 NA $0.25 NA FPL – Federal Poverty Level * If a school serves >60% free and reduced price lunch, rate increases $0.02. + If a school serves >40% free and reduced price breakfast, rate increases $0.28. (Not for paid meals) Reimbursement rates do not include an additional $0.2075 commodity value per lunch.Local Education Agencies (LEAs), often synonymous with school districts, are responsible forthe certification and verification of student eligibility for free and reduced price meals.Certification is the process in which an LEA deems a child eligible for free or reduced pricemeals based on information reported on his or her paper application. After students have beencertified for free or reduced price meals, verification is the process in which LEAs check theeligibility of a selected sample of students.Figure 1: Traditional Paper-based Certification Process for Free or Reduced Price Meals 1 2 3 1. Member of household fills out paper application. 2. Household sends paper application to LEA. 3. LEA reviews information and if eligibility requirements met, certifies student.1 http://www.cde.ca.gov/ls/nu/rs/rates0809.asp 4
    • Figure 2: Traditional Paper-based Verification Process for Free or Reduced Price Meals 2 1 3 5 4 6 1. LEA selects sample of certified students for verification. 2. LEA sends a letter to households to request verifying information. 3. Household collects requested information. 4. Household sends copies of information to LEA 5. LEA reviews information and if information meets eligibility requirement, student remains certified. 6. If household does not respond, child’s meal benefits are terminated.Although this traditional paper-based approach has enrolled millions of children, there are faultsthat keep eligible children from the nutritional benefits of school meals. We estimate that inCalifornia one in four children eligible for free or reduced price meals are not enrolled. Theresult is that more than 700,000 low-income children pay full price or go without meals duringthe school day.2 Two factors contribute to low enrollment: low rates of application submissionfrom eligible populations and the loss of enrolledchildren during verification because documentationwas not submitted to the school. In addition, the In California, more thanadministrative burden and paperwork involved inthe processing of all children applying for meal 700,000 low-income childrenbenefits can be significant. Both direct certification pay full price or go withoutand direct verification address the above concerns meals during the school day.by increasing eligible enrollment and reducingpaperwork for school administrators.2 Chandran, Kumar. Recess from the Recession: How School Meals Can Do More to Help StrugglingFamilies. Oakland, CA: California Food Policy Advocates. 12 Jan 2009http://www.cfpa.net/School_Food/backtoschool_2008.pdf. 5
    • Direct CertificationDirect certification enables LEAs to certify eligibility for free school meals, without anapplication from the household. LEAs can use information from another means-tested programto confirm that the family meets eligibility requirements. As an additional benefit to schooladministrators, any student directly certified for meal benefits is not subject to the verificationprocess.Legislative HistoryDirect certification was first authorized for use in The Child Nutrition and WIC ReauthorizationAct of 1989 (P.L. 101-147), which allowed for direct certification with Food Stamps (FS), Aid toFamilies with Dependent Children (AFDC), and the Food Distribution Program on IndianReservations (FDPIR). (AFDC later became Temporary Assistance for Needy Families (TANF),which is known in California as California Work Opportunities and Responsibility to Kids(CalWORKS).)Initially, direct certification was an optional process and its use grew gradually. By 1996 morethan 3 in 5 districts participating in NSLP nationwide conducted direct certification.3 The ChildNutrition and WIC Reauthorization Act of 2004 (P.L. 108-265) mandated the implementation ofdirect certification for all children in households receiving food stamp benefits by July 2008. In2005, California passed legislation requiring the California Department of Education (CDE) todesign and implement a computer match system using FS and CalWORKS to directly certifyschool meal eligibility.ProcessIn paper certification, each household submits an application reporting a means-tested programcase number (categorical application) or household income and size (income application).Categorical applications are certified when a valid CalWORKS or FS case number is provided.Income applications are certified by calculating percent of the federal poverty level (FPL) fromreported household income and size. The limit for free meals is 130 percent FPL and for reducedprice meals the limit is 185 percent. Traditional paper-based certification requires LEAs toprocess applications for every household applying for meal benefits. Paper certification requires LEAs to process applications for every household applying for meal benefits. Direct certification uses means-tested program participation to enroll students for benefits without an application from the household. .3 Cole and Logan. Data Matching in the National School Lunch Program: 2005 Volume 1: Final Report.Alexandria, VA: USDA FNS Office of Analysis, Nutrition and Evaluation, 2007. 6 Dec 2008http://www.fns.usda.gov/oane/menu/published/cnp/FILES/DataMatching-V1.pdf. 6
    • Direct certification uses information from another means-tested program to enroll students forbenefits without an application from the household. If a child is in a household participating inFS, CalWORKS or FDPIR, which in California have income limits below 130% FPL, the childcan be automatically enrolled for free meal benefits. Although FDPIR is authorized for directcertification, FS and CalWORKS are the programs most frequently used.BenefitsChildren, families and LEAs all benefit from direct certification. Any child whose householdreceives FS or CalWORKS does not need to have someone in the household fill out and send in apaper application. Families that previously did not apply because they didn’t understand theapplication, were afraid of negative immigration action, were unaware of eligibility or unable toreturn the application to schools will now have their children enrolled for meal benefits. LEAsbenefit by having reduced administrative paperwork, time and money spent on the processing ofapplications. Another benefit for LEAs is that because directly certified children are not subjectto selection for the verification sample, there is much less work to do for verification. LEAs alsobenefit because they do not have to choose between turning away a needy child in the lunch linebecause his or her family did not submit an application and picking up the cost of feeding thatchild.Current Use in CaliforniaAs of July 2008, federal law required all LEAs to conduct direct certification using FSparticipation data and most LEAs are also including CalWORKs in their efforts. There are twomethods of direct certification: state match and local match. At the beginning of the 2008 schoolyear, about 18% of LEAs had chosen to use the state match method, which represents about 26%of the state’s public K-12 schools.4 It is assumed that the rest of the schools are using localmatches.The State MatchThe state computerized match that was required by 2005 California legislation became availablefree-of-charge to all LEAs in the summer of 2007. The match is coordinated between theCalifornia School Information Services (CSIS), whomanages CDE’s student database, and the CaliforniaDepartment of Health Care Services (DHCS), who Any student with an invalidmaintains the database containing FS and address will be excluded fromCalWORKS information. Two times a year, in July the match. Only students thatand September, LEAs submit student enrollmentdata to CSIS. CSIS then compiles all the data have exact matches for fourreceived from participating LEAs and submits it to criteria — phonetic name,be matched. The student addresses submitted by date of birth, gender andLEAs is validated by an external service and anystudent with an invalid address (one that is not address — are consideredrecognized by the US Postal Service) will be matched.excluded from the match. At the same time, DHCS4 Correspondence with CSIS. 28 Aug 2008. 7
    • compiles a list of all school-age children in households participating in FS or CalWORKS fromtheir database which is updated monthly. First and last names of children in both lists areprocessed to simple phonetics, to account for data entry and spelling errors. When the two listsare processed, only students that have exact matches for four criteria — phonetic name, date ofbirth, gender and address — are considered matched. The resulting list of matched students issent to CSIS with an indication of eligibility, which is added to the students’ CSIS information.CSIS then notifies LEAs that they can download a list of matched children to be directly certifiedfor free meals. LEAs send letters to families of directly certified children to notify them of mealbenefit enrollment and inform them that no further action is necessary unless they would like toopt out of meal benefits. Since its implementation in 2007, the number of LEAs participating inthe state match has grown from 30 in 2007 to 227 in 2008.It is important to note that CDE is planning important changes to the state match system in 2009.With CDE’s implementation of the California Longitudinal Pupil Achievement Data System(CALPADS) in Fall 2009, CSIS will no longer manage the CDE student database. LEAs willsubmit their data through CALPADS rather than through CSIS. Also, CDE is planning toincrease the frequency of the match to monthly starting June 1, 2009. 8
    • Figure 3. Comparison of State Match and Local Match State Match Local Match State generates list of Local county office children participating in FS generates list of children LEA participating in FS and LEA and CalWORKS in generates list CalWORKS in county. generates list California. of students. of students. State matches lists by County/external service computer and generates list matches lists by computer of matched students based or manually and generates on exact match of name, list of matched students date of birth, gender and based on varying match address. criteria. State distributes lists to County distributes lists to LEAs at no cost. LEAs for a fee ($200-300). LEA certifies students on LEA certifies students on match list. match list. LEA notifies households LEA notifies households and updates benefit and updates benefit issuance issuance instrument. instrument. Households must respond Households must respond only if they wish to refuse only if they wish to refuse free meals. free meals.The Local MatchMany more LEAs are using the local match than the state match for direct certification, perhapsbecause the state match was only very recently made available. In 2006, large LEAs with studentenrollments of greater than 25,000 were required to implement a method of direct certificationand the only option available was the local match. Other LEAs that chose to implement beforetheir mandatory deadline would have also used the local match.The local match is similar to the state match in concept, but the details of the process are notstandardized. Most often, the LEA submits a list of enrolled students to the county, who matchesit to a list of children participating in FS and CalWORKS within the county. The resulting list ofmatched students is given to the LEA to conduct direct certification. Matches are generallyconducted at the end of July and some counties will conduct additional matches if requested bythe LEA. Counties charge the LEAs a fee for each match process conducted, usually about $200 9
    • to $300. Each county chooses different criteria to match by: phonetic name, gender and date ofbirth; name, date of birth, social security number (SSN) and address; or name, date of birth andSSN. Most LEAs report that the match is computerized, but a few smaller counties report that thematch is done manually. In addition to being done by the county, some LEAs contract with anindependent data processing service to conduct the match.Achieving the Best MatchIn theory, every child on the FS and CalWORKS list should be matched to his or her name on aschool enrollment list and directly certified. In other words, once a household with school agechildren is approved for FS or CalWORKS benefits, the children should automatically beginreceiving free school meals without the family having to take additional steps. Unfortunately,that is not the case. Often children are not matched, not because they are ineligible, but becauseof data entry errors or design flaws of the match. The question becomes: How can we make theCalifornia match the best match? The best match would be one in which the most eligiblechildren are matched without incorrectly matchingineligible children. The best match would also be amatch that is easy and accessible for LEA staff. LEA staff wants a system to:When we spoke to the food service technicians and • Match the most children,directors in California that conduct directcertification, they wanted a system that would match • Provide timely results, andthe most children, provide timely results and allow • Allow flexible access toflexible access to the match lists. The following are match lists.our recommendations to improve direct certificationin California.Recommendations for Improving the MatchFocus on the State MatchWith improvements over time, we believe that thestate match has the potential to be the best matchmethod for LEAs. Because the state match uses a Recommendation: LEAsstatewide list of FS and CalWORKS children, it can should switch to the statematch more children than the local match. For match or use the stateexample, if a student on a LEA’s enrollment list hasrecently moved from another county, they could be match in addition to thematched in the state match but not in the local match. county match.LEAs can request an updated list from CSIS at anytime during the year, enabling them to check if newlyenrolled students have been previously direct certified through the state match in a different LEA.In addition, the CDE plans to improve the state match by conducting matches on a monthly basisstarting on June 1, 2009, which will more accurately reflect the eligibility of childrenparticipating in FS or Cal. Finally, the state match is provided free-of-charge, so LEAs thatswitch to the state match will save money or LEAs that choose to use both the county and statematch will have no additional costs. Using both the state and the local match may lead to more 10
    • children being directly certified in a LEA because the one match may identify eligible childrenthat the other match may miss because of differing match criteria. With continued improvement,the state match can match more children than the local match at no cost to LEAs and LEAs willbe able to access results quickly and more frequently throughout the year. We recommend thatLEAs switch to the state match or use the state match in addition to the local match. For thatreason, the proceeding discussion and recommendations will pertain to the state match.Liberalize the Match CriteriaIt is critical that the criteria for the California state match accurately identify eligible children.Little testing has been done to identify criteria that will result in the best match. Also, there is alack of monitoring data of match results to inform match accuracy because state law precludedsuch test until January 1, 2009. Without comprehensive testing and regular monitoring, thematch is running blind and will continue to cause eligible children to miss out on benefits. Onepurported rationale for not testing the match criteria are concerns about protecting studentprivacy. But tests can be done that honor California’s important privacy protections. Other stateshave tested and fine-tuned match criteria within privacy regulations and Massachusetts has setbenchmarks of match coverage for their state match. While there may always be a portion ofstudents that will not be matched due to data entry errors, the match should be designed to captureas many eligible students as possible. We recommend that a comprehensive testing of criteriaoptions be conducted to identify the match criteria that will match the most eligible childrenwhile not matching ineligible children. Also, a benchmark of match coverage, such as thepercent of eligible children matched to school enrollment, should be set and monitored. If matchcoverage does not reach the benchmark, action should be taken to identify and remedy theproblem. Recommendation: A comprehensive testing of criteria options should be conducted to identify the match criteria that will match the most eligible children while not matching ineligible children. Also, a benchmark of match coverage… should be set and monitored. If match coverage does not reach the benchmark, action should be taken.In examining the California state match, we found that the match criteria may be too stringent,which is causing false negatives in the match — that is, eligible children not being matched. Ofall four criteria for match, (name, date of birth, gender and address) the address identifier may becausing the most false negatives. If households submit an invalid address or LEAs enter theaddress incorrectly, the state match will exclude the child, eligible or not, from the match. Evenif the address is valid, low-income children tend to move frequently and the address listed in FSor TANF records may not match the one listed in school district records. Finally, the addressidentifier limits the LEAs that can participate in the state match. Some LEAs may not have asystem that stores addresses in the form requested by CSIS or they may not have the staffing orsupport to submit it to CSIS. Address or any geographic identifier is not required to be included 11
    • in criteria for a direct certificationmatch. Only one out of the forty-four Recommendation: The match criteriastates using direct certification in 2005 should be loosened by eliminating anyrequired it for state or local match.5 Werecommend that in testing for best match identifiers, such as address, that limitcriteria, the match criteria be loosened the number of LEAs able to participateby eliminating any identifiers, such as and result in eligible children notaddress, that limit the number of LEAs being matched.able to participate and result in eligiblechildren not being matched.Utilize Multiple MatchesMultiple matches is a strategy that is used by a number of states to improve the accuracy of astate match. Multiple matches involve a primary match that has stringent criteria and a secondmatch that does not include previously matched children and has looser criteria. The primarymatch will accurately capture a portion of eligible children, while the second match will catch children that may have typos in the primary match criteria that are causing them to not be Recommendation: A multiple matched. Using this method ensures that match process should be children that are eligible do get directly certified in the second match. We implemented to increase the recommend that in testing for best match number of eligible children criteria, a multiple match process be matched. implemented to increase the number of eligible children matched.Unmatched Kids and Sibling MatchesAll possible effort should be made to ensure that eligible children are matched. It should not beassumed that the match is accurate. Instead, a list of unmatched kids should be created for twopurposes: to provide LEAs with additional information and to identify eligible unmatchedsiblings.Unmatched children are children that are on the list denoting participation in Food Stamps andCalWORKS, but did not match on all the criteria to the information submitted by school districts.If LEAs could access a list of unmatched children in their county or statewide, they could use thatinformation to find and correct possible reasons the child did not match, such as a misspelledaddress, unintentional typo or old address. This sort of feedback from the match process will bevery helpful for the school district and also for improving the state match process.When talking to food service directors and technicians, they frequently mentioned beingfrustrated when a child in a household is matched, but a sibling of that child is not matched.Oregon is the only state that has implemented a sibling match to address the problem. After theprimary match has occurred, the sibling match creates a list of unmatched FS and TANF children5 Cole and Logan 2007. 12
    • that have the same head of household asmatched FS and TANF children.6 Thosechildren are eligible for direct certification Recommendation: Additionalunder the 2004 Reauthorization legislation that action should be taken withrequires direct certification for any “child who unmatched children on the FS andis a member of a household receiving CalWORKs list, such as making theassistance under the food stamp program.”The sibling match list can then be added to the list available to LEAs and creatingmatch list and he or she can be directly a sibling match.certified. As the sibling issue is prevalentnationwide and in California, it makes sense toimplement a sibling match to ensure that all children in FS and CalWORKS households arematched for direct certification. We recommend that additional action be taken with unmatchedchildren on the FS and CalWORKs list, such as making the list available to LEAs and creating asibling match, to ensure that more eligible children are matched.Continue with Plans to Increase Match FrequencyThe current frequency and timing of the match does not meet the needs of LEAs to match alleligible children. Many LEAs expect a significant number of new students to enroll in the firstweek of school and depending on what the start date of the school year, new students often arenot captured in the July match and may or may not be captured in the September match. Also,there can be a significant time between the submission of school data and the return of the matchlist in which schools have received new enrollees.Staff of LEAs commented that it would be helpful to them if they were able to quickly downloadupdated lists of matched children. This would enable them to capture new enrollees and alsostudents that enroll throughout the school year. This improvement would also work to directlycertify children in households that enter FS or CalWORKS after the September match. BecauseFS and CalWORKS databases are updated monthly to include new recipients, an updated list ofall eligible children could be matched toupdated school enrollment lists each month. Amonthly match would allow LEAs to use Recommendation: CDE shoulddirect certification to capture all eligiblestudents throughout the school year, whether continue with plans to increase thethey are new to the school or to the FS or match frequency to monthly andCalWORKS program. CDE’s current plans to CSIS should provide freedom toincrease the match frequency to monthly access the match list in a variety ofstarting June 1, 2009 will greatly improveLEAs ability to directly certify students that ways.begin participating in FS or CalWORKSduring the school year.6 Cole and Logan. 2007. 13
    • It is important to note that because Reauthorization legislation states that certification status iseligible for one year, each month the list should not be replaced by the new list, but be mergedwith the new list, to avoid children losing benefits. As the updated match is maintained in theCSIS (or future CALPADS) database, LEAs could be given the ability to use multiple ways toaccess the match list; staff could download a school-year–to-date match list or a monthly matchlist or search for the match status of an individual student. We recommend that CDE continueswith plans to increase the state match frequency to monthly and that CSIS (or CALPADS)provides freedom to access the match list in a variety of ways, to capture more eligible studentsand make it easier for LEA staff to conduct direct certification.Improved CommunicationsLastly, LEA staff requested that additional communication and technical support be provided toimplement and improve direct certification activities. Some school staff were unaware that thestate match was available at no charge and that CSIS was providing on-site and web trainings.Although communication is clear in written bulletins and notices, it may not be reaching the staffresponsible for enrolling students in meal programs. Smaller or rural LEAs may not have asmuch administrative support as larger LEAs and need additional assistance in implementing thematch. For example, in 2008, CSIS added a data field for addresses to its “extended client”option in order to facilitate the use of the state matching system for small LEAs that do not haveautomated student information systems. More actions like this could be taken to accommodatethe needs of smaller LEAs. We recommend that the CDE increase communications regarding theavailability and continual improvements of the state match. Both CDE and CSIS should provideadditional outreach and trainings, particularly for small rural LEAs, to increase participation inthe state match. Recommendation: CDE should increase communications regarding the availability and continual improvements of the state match. Both CDE and CSIS should provide additional outreach and trainings. 14
    • Direct VerificationDirect verification avoids the hassles of paper verification by using means-tested programparticipation information to check eligibility. It also reduces the number of eligible children wholose free or reduced price meals. When children are directly verified for free or reduced pricemeals, no additional documentation needs to be requested from families and then processed byLEAs.Legislative HistoryBefore 2004, direct verification allowed LEAs to use the FS, TANF and FDPIR programinformation to verify categorical applications (reporting case numbers), but not incomeapplications (reporting household income and size). With the passage of the Child Nutrition andWIC Reauthorization Act of 2004, Medicaid and State Children’s Health Insurance Program(SCHIP) can also be used and both categorical and income applications can be directly verified.The process continues to be optional for LEAs, but becomes a much more powerful tool with thechanges made by the most recent Reauthorization.ProcessIn paper verification, a sample of all students certified for free and reduced price meals as ofOctober 1st must be verified. Directly certified students are not included in the pool of studentssampled to be verified. Some LEAs have options for choosing how to sample their pool ofcertified students. In most cases, the sample is three percent of the pool and composed of mostlyincome applications. For all students in the sample, the LEAs send a letter to the householdrequesting documentation of program participation or income, depending on whether the studentwas certified based on a categorical or income application. On average, one out of three studentsasked to respond with documentation for verification loses their meal benefit because the LEAdoes not receive verification paperwork.7 It may be that households do not want to share incomedocumentation, do not have income documentation or have language barriers that make itdifficult to understand the letter. As a result, many eligible children lose free or reduced pricemeal benefits.Similar to direct certification, direct verification uses a match to create a list of students eligiblefor free or reduced price meals. If a student is on the match list and in the verification sample, thestudent is directly verified for meal benefits and no letter is sent to the household .BenefitsDirect verification benefits children, families and LEAs. Children that are eligible for mealbenefits are able to retain them and families do not need to return documentation to LEAs. Theworkload of LEA staff decreases as less time is spent trying to contact households and processdocuments. A study by the U. S. Department of Agriculture’s Food and Nutrition Service(USDA FNS) shows that paper verification takes eighty-one minutes for each student, while7 Cole and Logan. 2007. 15
    • direct verification only takes six minutes.8 Direct verification, like direct certification, has thepotential to increase eligible enrollment and reduce administrative burden.Best UsesThere are circumstances in which direct verification is best used. In essence, it is an interim stepbetween the paper certification and verification world and a world in which there is complete andeffective direct certification. To be relevant and effective, the means-tested programs used fordirect verification must be different than those used for direct certification. If FS andCalWORKS are used for direct certification, theoretically all children in FS and CalWORKS willbe directly certified and none will be in the verification sample to be directly verified. In reality,some children will not be matched in direct certification and may be in the sample to be directlyverified, but the more effective the direct certification process, the smaller the number will be.However, if Medicaid and SCHIP are used in addition to FS and CalWORKS for directverification, there will be a substantial list of children that can be directly verified and the processwill actually useful to LEA staff conducting verification.Secondly, the higher the non-response rate to verification letters, the more valuable directverification will be. In areas where many eligible households are unlikely to respond to theverification request for reasons such as language or literacy barriers, direct verification will helpvulnerable families retain meal benefits and will reduce paperwork for school personnel. In areaswith a high response rate to verification letters, the paperwork reduction will be more modest, butdirectly verified families will still be spared an additional step.Current Use in CaliforniaDirect verification has never been mandatory, so although some LEAs have explored the option,very few LEAs actually use direct verification. One of the reasons is that direct verification hasnot included data from Medi-Cal, the Medicaid program in California, or Healthy Families, theSCHIP program in California. Of the LEAs that tried direct verification, all said that they usedonly FS and CalWORKS. As mentioned previously, if the same group of programs is used fordirect certification and direct verification, LEAs will find little benefit because most children willbe directly certified and not subject to verification. There was also confusion among staffregarding the ability to use direct verification on income applications. Most staff thought thatdirect verification could only be used for categorical applications (applications with FS or Recommendation: Direct verification should be used when a system is in place to make use of Medi-Cal and Healthy Families data. In addition, communications to LEA staff should clarify that direct verification can be used for both categorical and income application.8 Cole, Logan, and Hoaglin. Direct Verification Pilot Study - First Year Report. Alexandria, VA: USDAFNS, Office of Analysis, Nutrition and Evaluation, 2007. 4 Dec 2008<http://www.fns.usda.gov/OANE/MENU/Published/CNP/FILES/DirectVerificationYear1.pdf>. 16
    • CalWORKS case numbers) and as income applications make up the majority of verificationsamples, direct verification did not prove useful. We recommend that direct verification be usedwhen a system is in place to make use of Medi-Cal and Healthy Families data. In addition,communications to LEA staff should clarify that direct verification can be used for bothcategorical and income applications. 17
    • Addition of Medi-Cal to Direct Certification and Verification in CaliforniaLegislative AuthorityThe recent passage of Assembly Bill 2300 requires the CDE to develop and implement acomputerized state match for direct certification and direct verification of free and reduced pricemeals using Medicaid data. The 2004 federal Reauthorization allowed for Medicaid and SCHIPto be used as programs for direct verification, but not direct certification. It could be interpretedto allow for pilot programs that examine the potential of using Medicaid and SCHIP in directcertification. The act states that Medicaid participation confirms eligibility for free meals in statewith Medicaid income limits at or below 133% FPL. For Medicaid or SCHIP programs that haveincome limits above 133% FPL, an indicator of income eligibility verifies free or reduced pricemeal status.Potential of Medi-CalIn California, the potential for Medi-Cal and Healthy Families inclusion in direct certification anddirect verification is staggering. Because of income eligibility guidelines, all two million childrenin Medi-Cal and an estimated four hundred thousand children in Healthy Family are eligible forfree and reduced price meals. That is 3.5 times the number of children in FS and 5.5 times thenumber of children in CalWORKS.9 By including Medi-Cal and SCHIP data in the verificationprocess, the children in these programs that submitted a paper application will not have to returndocumentation of participation or income for verification. Inclusion in direct certification is farmore powerful: all of the 2.4 million children can be matched and automatically enrolled for free meals without application. Current direct certification does capture children that are participating in FS or Direct certification with CalWORKS, but 70% of children in Medi-Cal and Medi-Cal could yield 1.6 Healthy Families do not participate in other programs million more children being and therefore cannot10 benefit from current direct certification efforts. We estimate that direct enrolled for free meals. certification with Medi-Cal could yield 1.6 million more children being automatically enrolled for free meals.ProcessFor California, the inclusion of Medi-Cal in direct certification or direct verification will berelatively simple as an addition to the existing computerized state match. All Medi-Cal childrenmay be certified for free meals because the income limit is 133% FPL for very young childrenand 100% FPL for most school age children (See Figure 4). Therefore Medi-Cal participationdata will be added to FS and CalWORKS data to create a list of either children to be matched fordirect certification or direct verification. The list is then matched and made available for use byLEAs. By using the same processused for FS and CalWORKS, the inclusion of Medi-Cal shouldnot be difficult.9 California Health Information Survey. AskCHIS. 12 Jan 2009.<http://www.askchis.com/main/default.asp.>10 California Health Information Survey. AskCHIS. 18
    • The addition of Healthy Families data might be more complicated. In Healthy Families, mostschool-age children in Healthy Families have incomes between 100% and 250% the FPL.Without income and household size or percent FPL data, it is impossible to know whether theyare eligible for free meals, reduced price meals or neither. If the information is available, it isonly a matter of calculating and categorizing children to the appropriate eligibility status, but ifthe information is not available, it will pose a major barrier to the Healthy Families being usefulfor the purposes of direct certification or direct verification.Figure 4. Difficulty Matching Medi-Cal, Healthy Families and School Meal Income Eligibility Children Eligible for Medi-Cal Eligible for Healthy Families age 1-5 Children Eligible for Medi-Cal Eligible for Healthy Families age 6-18 % of FPL 0 100 133 185 250 All children Eligible for free meals Eligible for reduced price mealsRecommendationsIn California, the income limits of Healthy Families and the lack of income data for HealthyFamilies children poses a challenge for inclusion of Healthy Families in direct certification anddirect verification. Without income information for participants in Healthy Families, the childrenin the program with incomes between 133% and 185% FPL cannot be directly certified orverified for reduced price meals and the portion of children between 100% and 133% FPL willmiss out on free meal benefits. The options are then to 1) use only Medi-Cal data for free mealeligibility, 2) use young siblings in Medi-Cal to identify older children eligible for free meals or3) include income information at the state level in order to use Healthy Families data to identifychildren eligible for free and reduced price meals.In the first option, where only Medi-Cal data is used, young children ages 1-5 that are attendingschool will be identified as eligible for free meals because the income limit for that age range is133% FPL. But for most children of school age (6-18), the income limit is 100% FPL. All Medi-Cal children age 6-18 will be identified as eligible for free lunch, but children that are in HealthyFamilies and have incomes between 100% and 133% FPL will not be identified for free meals.The second option is to use young siblings age 1-5 to identify households that have incomes at orbelow 133% and then include older siblings in Healthy Families to be matched for free meals.Unfortunately, it would not capture students in Healthy Families with incomes from 100% to133% FPL that do not have younger siblings. Both the first and second options will not captureany students in Healthy Families that are eligible for free or reduced price meals. 19
    • The final and most ideal option is to explore the possibility of including income information inthe state level database for Healthy Families children. Washington State also faced the sameissue and was able to get income data included at the state level.11 If it is possible in California tochange the state level data to include income information, all children in Medi-Cal and HealthyFamilies will be able to be identified for free or reduced price meals. We recommend that CDEpursues the inclusion of income information for Healthy Families children in the statewidedatabase to facilitate direct certification and direct verification for those children. Recommendation: CDE should pursue the inclusion of income information for Healthy Families children in the statewide database to facilitate direct certification and direct verification for those children.Another barrier to full inclusion of the Medi-Cal and Healthy Families data into directcertification and direct verification is confusion regarding the federal authority forimplementation. The federal authority is clear in authorizing the inclusion of the programs fordirect verification; however, authority for using the programs in direct certification is only forpilot programs. If the inclusion of the two programs in direct certification is designed as a pilotproject, then it can be implemented. Luckily, the design and work needed to include theprograms in direct certification is the same work that would be done to use program data for indirect verification alone.Recently, CDE has acquired USDA funding to design and implement a direct verification matchthat uses FS, CalWORKS, Medi-Cal and Healthy Families. When federal authority is availablefor direct certification, the same matching process can be used for direct certification with little orno additional work. We recommend that the CDE use the design and implementation efforts ofthe Medi-Cal and Healthy Families direct verification system to implement direct certification inCalifornia as a pilot program or, if and when federal authority is clarified, as a permanentstatewide effort. When Medi-Cal and Healthy Families is used for direct certification, directverification will be a somewhat redundant process and could be phased out when it is determinedthat direct certification is reaching all children eligible for it. Recommendation: We recommend that the CDE use the design and implementation efforts of the Medi-Cal and Healthy Families direct verification system to implement direct certification in California as a pilot program or, if and when federal authority is clarified, as a permanent statewide effort.11 Cole, Logan and Hoaglin. 2007. 20
    • ConclusionsCalifornia is beginning its journey towards fully realizing the potential of direct certification anddirect verification for enrolling children for free and reduced price meals. There are three actionswe can take to achieve the most effective processes: improve the direct certification system,implement direct verification and include Medi-Cal and Healthy Families in the system. With allLEAs conducting direct certification, the CDE can make important improvements to the statematch to ensure that it is accurate and serves the needs of LEAs. Implementing direct verificationis an important interim step between the current direct certification system and one that shouldeventually include Medi-Cal and Healthy Families. When we have a system that allows low-income children and families to easily access nutrition at school without the hassles of paper, wewill have achieved a great thing for the health and future of California.CFPA’s recommendations for effective direct certification and direct verification:Direct Certification • LEAs should switch to the state match or use the state match in addition to the county match. • Comprehensive testing of criteria options should be conducted to identify the match criteria that will match the most eligible children while not matching ineligible children. • A benchmark of match coverage, such as the percent of eligible children matched to school enrollment, should be set and monitored. If match coverage does not reach the benchmark, action should be taken to identify and remedy the problem. • The match criteria should be loosened by eliminating any identifiers, such as address, that limit the number of LEAs able to participate and result in eligible children not being matched. • A multiple match process should be implemented to increase the number of eligible children matched. • Additional action should be taken with unmatched children on the FS and CalWORKs list, such as making the list available to LEAs and creating a sibling match. • State match frequency should be increased to monthly and CSIS should provide freedom to access the match list in a variety of ways. • CDE should increase communications regarding the availability and continual improvements of the state match. Both CDE and CSIS should provide additional outreach and trainings.Direct Verification • Direct verification should be used when a system is in place to make use of Medi-Cal and Healthy Families data. • Communications to LEA staff should clarify that direct verification can be used for both categorical and income application. 21
    • Adding Medi-Cal and Healthy Families • CDE should pursue the inclusion of income information for Healthy Families children in the statewide database to facilitate direct certification and direct verification for those children. • CDE should use the design and implementation efforts of the Medi-Cal and Healthy Families direct verification system to implement direct certification with Medi-Cal and Healthy Families in California as a pilot program or, if and when federal authority is clarified, as a permanent statewide effort. 22
    • ReferencesChandran, Kumar. Recess from the Recession: How School Meals Can Do More to HelpStruggling Families. Oakland, CA: California Food Policy Advocates. 12 Jan 2009http://www.cfpa.net/School_Food/backtoschool_2008.pdf.Cole, Nancy, and Christopher Logan. Data Matching in the National School Lunch Program.Approaches to Direct Certification and Direct Verification: Guide for State and Local Agencies.Alexandria, VA: U.S. Department of Agriculture, Food and Nutrition Service, Office of Analysis,Nutrition and Evaluation. 6 Dec 2008http://www.fns.usda.gov/oane/menu/published/cnp/FILES/DataMatchingGuide.pdf.---. Data Matching in the National School Lunch Program: 2005 Volume 1: Final Report.Alexandria, VA: U.S. Department of Agriculture, Food and Nutrition Service, Office of Analysis,Nutrition and Evaluation, 2007. 6 Dec 2008http://www.fns.usda.gov/oane/menu/published/cnp/FILES/DataMatching-V1.pdf.---. Data Matching in the National School Lunch Program: 2005 Volume 2: Select Case Studies.Alexandria, VA: U.S. Department of Agriculture, Food and Nutrition Service, Office of Analysis,Nutrition and Evaluation, 2006. 6 Dec 2008http://www.fns.usda.gov/oane/menu/published/cnp/FILES/DataMatching-V2.pdf.---. Preliminary Report on the Feasibility of Computer Matching in the National School LunchProgram. Alexandria, VA: U. S. Department of Agriculture, Food and Nutrition Service, Officeof Analysis, Nutrition, and Evaluation, 2005. 4 Dec 2008http://www.fns.usda.gov/oane/menu/published/cnp/FILES/NSLPDataMatch.pdf.Cole, Nancy, Christopher Logan, and David Hoaglin. Direct Verification Pilot Study - First YearReport. Alexandria, VA: U.S. Department of Agriculture, Food and Nutrition Service, Office ofAnalysis, Nutrition and Evaluation, 2007. 4 Dec 2008http://www.fns.usda.gov/OANE/MENU/Published/CNP/FILES/DirectVerificationYear1.pdf.Neuberger, Zoe. Implementing Direct Certification: States and School Districts Can Help Low-Income Children Get the Free School Meals for Which They Are Eligible. Washington, DC:Center for Budget and Policy Priorities, 2006. 8 Dec 2008 http://www.cbpp.org/8-11-06fa.pdf.---. Reducing Paperwork and Connecting Low-Income Children with School Meals:Opportunities under The New Child Nutrition Reauthorization Law. Washington, DC: Center forBudget and Policy Priorities, 2004. 8 Dec 2008 http://www.cbpp.org/11-16-04fa.pdf.---. Summary of Changes Made to the Certification and Verification Processes in the NationalSchool Lunch and School Breakfast Programs by the Child Nutrition and WIC ReauthorizationAct of 2004. Washington, DC: Center for Budget and Policy Priorities, 2004. 8 Dec 2008http://www.cbpp.org/8-18-04fa.pdf. 23
    • U.S. Department of Agriculture, Food and Nutrition Service, Child Nutrition Programs.Eligibility Manual for School Meals. 2008. 4 Dec 2008http://www.fns.usda.gov/cnd/governance/notices/iegs/EligibilityManual.pdf. 24
    • Appendix A: Application for Free and Reduced Price Meals California Department of Education March 2008 Nutrition Services Division (Place School District or Agency Name Here) FOR SCHOOL USE ONLY – ELIGIBILITY DETERMINATION HSHLD SIZE: HSHLD INCOME: $ APPLICATION FOR FREE AND REDUCED-PRICE MEALS FREE: REDUCED: DENIED: OR FREE MILK FOR SCHOOL YEAR _________ YEAR RND TRACK: FREE with: FS / CalWORKs / Kin-GAP / FDPIR COMPLETE AND RETURN THIS APPLICATION TEMPORARY FREE UNTIL: Direct Certified as: H M R EP TO THE SCHOOL (45 calendar days from date of determination) DETERMINING OFFICIAL: DATE: 2nd Review: SECTION A. ALL HOUSEHOLDS COMPLETE THIS SECTION VERIFICATION OFFICIAL: DATE: Follow-up: FOOD STAMP (FS), FOSTER STUDENT / CHILD INFORMATION CALWORKS, KIN-GAP, FOR SCHOOL CHILD USE ONLY OR FDPIR BENEFITS IF YES, COMPLETE ONE IF YES, ENTER APPLICATION PER SCHOOL YES/ YES/ LAST NAME FIRST NAME CASE NUMBER FOSTER CHILD. ENTER STUDENT ID NAME NO NO BELOW: CHILDS MONTHLY PERSONAL-USE INCOME 1. 2. 3. 4. 5. If you entered a Food Stamp, CalWORKs, Kin-GAP, or FDPIR case number for each child in Section A, or if this application is for a Foster Child and you entered his/her monthly personal-use income, skip Section B and complete Section C. SECTION B. HOUSEHOLD MEMBERS AND THEIR MONTHLY INCOME (IF ANY) (1) List all adult household members, regardless of income. (2) Indicate amount(s) and source(s) of income for those adult household members with income last month, (3) Enter any income received last month by/for a child from full-time or regular part-time employment, SSI, or Adoption Assistance payments; and (4) If amount last month was more/less than usual, enter the usual amount. GROSS EARNINGS WELFARE FOR SCHOOL PENSION, ANY OTHER FROM WORK BEFORE BENEFITS, CHILD USE ONLY: FULL NAME RETIREMENT, MONTHLY DEDUCTIONS, SUPPORT, ALIMONY TOTAL MONTHLY SOCIAL SECURITY INCOME INCLUDE ALL JOBS PAYMENTS INCOME 1. 2. 3. 4. 5. California Education Code Section 49557(a): Applications for free and reduced-price meals may be submitted at any time during a school day. Children participating in the National School Lunch Program will not be overtly identified by the use of special tokens, special tickets, special serving lines, separate entrances, separate dining areas, or by any other means. Privacy Act Statement: National School Lunch Act (Section 9) requires that, unless your childs Food Stamp, CalWORKs, Kin-GAP, or FDPIR case number is provided, you must include the social security number of the adult household member signing the application or indicate that the household member signing the application does not have a social security number. Provision of a social security number is not mandatory, but the application cannot be approved if a social security number is not provided or an indication is not made that the signer does not have such a number. The social security number may be used to identify the household member in carrying out efforts to verify correct information provided on the application. These verification efforts may be carried out through program reviews, audits, and investigations; and may include contacting employers to determine income, contacting the State’s Employment Development Department or local welfare offices to determine the amount of benefits received, and checking the documentation produced by household members to prove the amount of income received. Reporting incorrect information may result in loss or reduction of the household’s program benefits, or in administrative claims and/or legal actions against household members. SECTION C. ALL HOUSEHOLDS READ AND COMPLETE THIS SECTION I certify that all of the above information is true and correct and that all income is reported. I understand that this information is given for the receipt of Federal funds, that school officials may verify the information on the application, and that deliberate misrepresentation of the information may subject me to prosecution under applicable State and Federal laws. SIGNATURE OF ADULT HOUSEHOLD MEMBER COMPLETING THIS FORM TELEPHONE NUMBER DATE PRINTED NAME OF ADULT HOUSEHOLD MEMBER SIGNING THIS APPLICATION SOCIAL SECURITY NUMBER (WRITE “NONE” IF N/ A) ADDRESS CITY STATE ZIP CODE SECTION D. CHILDREN’S RACIAL AND ETHNIC IDENTITIES (Optional) 1. Mark one or more racial identities: American Indian or Asian Black or Native Hawaiian or White Alaska Native African-American Other Pacific Islander 2. Mark one ethnic identity: Of Hispanic or Latino Origin Not of Hispanic or Latino Origin This Institution is an Equal Opportunity Provider. Rev. June 2005 25